Superior, With a Serious Rodent Problem: Who Pays for a Food Safety Audit, and What That Buys

1. Introduction: the document our work is bought against

Commercial pest control in food premises is very largely sold against audit requirements. A client needs a documented programme, service records, a site map and a trend report because an auditor will ask for them.

Which makes what an audit actually establishes a question this trade has a direct interest in, and one we have not previously examined.

1.1 What this paper is not

An argument that audits are worthless, or that auditors are dishonest. It is an argument that the structure of the arrangement produces predictable failures, and that a passed audit is weaker evidence than the people relying on it believe.

2. What the audit found

The document, and its date.

The conclusion quoted above appears in a March 27, 2008 report prepared for an institute that performs audits for major food companies, a copy of which was obtained by a national newspaper.¹

2.1 Who the audit was for

The auditor was inspecting the plant on behalf of a major cereal manufacturer and other food companies.¹

So there are three parties: the buyer who wants assurance, the supplier being examined, and the audit firm. Section 5 concerns which of them wrote the cheque.

3. What was actually there

What investigators found afterwards.

Federal investigators later discovered that the dilapidated plant was ravaged by salmonella and had been shipping tainted peanuts and paste for at least nine months, too late to prevent one of the nation's worst known outbreaks of food-borne disease in recent years.¹

3.1 The word dilapidated

That is not a description of a subtle hygiene lapse. A dilapidated building is visible from the car park, and this journal's articles on exclusion have made the point repeatedly that structural condition is the foundation of any pest programme.

3.2 The timing

Shipping contaminated product for at least nine months, with a superior rating issued during that period. The audit did not merely miss a latent risk; it was conducted while the failure was occurring.

4. The rodent problem

The detail that puts this article in this journal.

Although the facility was very poorly maintained and had a serious rodent problem, the auditor had several months before given the firm a superior rating.²

4.1 What that means about the instrument

Rodent activity is among the most visible conditions in a food plant. Droppings, gnawing, runways and smears are exactly the evidence this journal has described as accumulating in accessible places before structural consequences appear.

An audit that produced a superior rating on a site with a serious rodent problem was not failing at a subtle task. It was failing at the one most amenable to direct observation.

4.2 The uncomfortable reading for this trade

Whatever pest control arrangement that facility had, it was either not working or not happening, and the audit did not detect either. A pest management programme that satisfies an audit is not thereby a programme that controls pests, and this is the case that demonstrates it.

5. Who was paying

The structural fact.

The auditor was inspecting the plant on behalf of its customers, and the Peanut Corporation was paying him for his efforts.¹

5.1 The shape of the conflict

The party whose conduct is being assessed selects the assessor, negotiates the terms, and pays the invoice. The party relying on the result does none of those things.

This journal's credence goods article described markets where the buyer cannot assess quality and found liability to be the only effective remedy. Here there is a further twist: the person who commissions the assessment is the person being assessed, so even the assessment is a credence good bought by the wrong party.

5.2 Why the customers did not pay directly

Because each supplier has many customers, and having every customer commission its own audit would multiply the cost and the disruption. One audit sold to many buyers is efficient, and the supplier is the natural party to arrange it.

The arrangement exists for a good reason and produces the conflict as a side effect, which is why the remedy in §19 is disclosure and independence requirements rather than abolition.

5.3 What this does not imply

That any individual auditor was corrupt. The mechanism does not require it, and §6 shows the auditor in this case trying to do more work rather than less.

6. The single day

The detail we find most damning, precisely because it is not about dishonesty.

In auditing the plant, the auditor became concerned about his ability to check the plant thoroughly and asked for more than the one day allotted. The audited company agreed to pay for the additional time, but only in future audits.¹

6.1 Reading that exchange

The auditor identified that the allotted time was insufficient and said so. The party paying declined to fund more, for this audit, while agreeing in principle for later ones.

There were no later ones that mattered. The rating went out on the basis of the day that had been purchased.

6.2 The counterfactual nobody can test

Whether a second day would have found it. An auditor with more time might have looked into the voids, followed the rodent evidence, and written a different report.

Or might not have, since §11 says the method was documents, programmes and equipment. Time helps only if the scope allows for the thing time would reveal.

6.3 Why this is the clearest illustration in the case

Everything else can be argued about. This is a documented instance of the person doing the work asking for what the work required, and the person being examined deciding the budget.

That is not a failure of the auditor's diligence. It is the payment structure determining the depth of the examination, which is what the conflict of interest objection predicts.

7. The scale of the consequences

What followed.

The outbreak is described as one in which nine are believed to have died and an estimated 22,500 were sickened.¹ The contamination caused a recall of over 4000 different foods,² and questions were raised about the 2,100 companies who purchased product from this plant.⁸

7.1 The number of downstream customers

Two thousand one hundred companies bought product from that plant,⁸ many of them large and well known. Each of those presumably ran its own supplier assurance process, and the great majority of them will have relied on the same certificate.

A single audit document propagated as assurance across two thousand supply relationships, which is what makes an audit failure different in kind from an inspection failure at one site.

7.2 The recall figure is the systemic one

Four thousand distinct food products traced to one facility. A single audit failure propagated through a supply chain into thousands of items on shelves.

8. Reconciling the casualty figures

The sources disagree and we should say so rather than pick the largest.

One account gives nine believed to have died and an estimated 22,500 sickened.¹ Another gives at least nine deaths and nearly 700 illnesses.⁴ A third states the outbreak took the lives of 7 persons.²

8.1 Why the illness numbers differ by a factor of thirty

Our reading is that around seven hundred is the laboratory-confirmed case count and the larger figure is a modelled estimate of total infections, since most foodborne illness is never cultured, reported or linked to a source.

That is inference rather than a sourced explanation, and we flag it. It is also exactly the detection problem the previous article in this journal described, appearing in epidemiology: the confirmed count is a function of how hard anybody looked.

8.2 The death figures

Seven and nine appear in different accounts.¹²⁴ We have no basis for choosing and have quoted the range.

9. The second opinion

A detail that complicates the picture usefully.

The same company scored a Superior rating from one auditing firm and 91 per cent from another.³

A separate audit produced what officials said was a low score for their scheme. But the company that paid for the audit, a large insurer, then sold the peanut company insurance to cover the costs of recalling products.¹

9.1 Two documents, one plant, one period

Superior from one firm and 91 per cent from another, with a third scheme recording what it regarded as a low score.³¹ Same facility, overlapping period, three different characterisations.

That spread is itself informative. If audits measured the plant, they would agree; if they measure an interaction between a scheme, a scope, a day and an auditor, they would not.

9.2 What that second arrangement shows

An audit commissioned by an insurer, producing a low score, followed by that insurer writing recall cover for the audited firm.

We are not going to characterise that beyond reporting it. What it demonstrates is that the identity of the party paying for an audit shapes what the audit is for, and that different payers produce different documents about the same plant in the same period.

10. It was not an isolated case

The pattern, which is what elevates this from an anecdote.

In 2010 a salmonella outbreak was traced to filthy conditions at two Iowa farms where hundreds of millions of eggs were recalled, and one of those farms had received a superior rating from the same auditing organisation.⁴

A critical commentator states that the organisation has given superior plus plus ratings to some of the worst food offenders in the past decade.⁹

10.1 The status of that second claim

It is a strongly worded assertion from a food safety blog rather than a systematic review.⁹ We include it as characterisation and would not rely on it as evidence.

The Iowa egg case is separately reported and is the one doing the work here.⁴

10.2 The buyer response

After the peanut case, one major purchaser openly stated that they are reviewing how they qualify food safety suppliers after its third-party auditor gave the Georgia plant a superior rating.⁸

11. What the auditor said they were doing

The audit firm's own description of its method, which we think is the most important quotation in this article.

Their approach involved checking documents, making sure programs are in place, checking equipment at a single point in time.⁴

11.1 The phrase at a single point in time

It appears in a statement made after the outbreak, by a spokesman explaining what the audit had covered.⁴ Read one way it is a defence; read another it is the specification.

11.2 That is an accurate description of an audit

It is not an evasion. Checking that documented programmes exist and that equipment is in order at a point in time is what a conformance audit does, and the firm is describing its product correctly.

The problem is the gap between that product and what buyers understood themselves to be purchasing.

12. Why checking documents is the structural problem

The point where this becomes directly about pest control.

A documented pest management programme consists of a contract, a site plan, device placements, service reports, trend analysis and corrective action records. All of those can be complete and correct in a facility with a serious rodent problem.

12.1 The two questions that come apart

Does a programme exist and is it documented. Is the facility free of pests. An audit of the first kind is a check on paperwork; only the second is a check on outcome.

This journal has made a version of this argument about our own service reports, in the article on detection, where a finding of no activity observed records an outcome without the effort behind it. An audit that verifies our documentation inherits whatever weakness the documentation has.

12.2 The case where the two agree

In fairness, documentation and outcome usually correlate. A facility maintaining proper records, acting on trend data and closing out corrective actions is generally a facility that is also controlling pests, because the same management attention produces both.

The correlation is why auditing documents works most of the time. It fails precisely where a facility is willing to maintain the paperwork and not the plant, which is the case where detection matters most and where §14's week of preparation becomes rational.

12.3 Why documentation is audited rather than outcome

Because outcome is hard to establish in a day, and documents are not. A rodent population is cryptic, nocturnal and concentrated in voids, which the previous articles in this journal have covered at length.

The instrument measures what is measurable in the time purchased, which returns to §6.

13. What the audited party controls

The terms, which are set by private contract.

Whether audits are announced or unannounced, whether they cover an entire production facility or just the portions involved in manufacture of a particular product are issues which are agreed upon by the customer and supplier without input from, or knowledge of, any regulatory entity. In some cases the contracting parties even specify the maximum amount of time allowed to conduct an audit.⁵

Under the contract, the auditee can restrict the scope of the audit, stop an audit, or simply cancel it.²

13.1 Which of these a regulator would control

All of them. A statutory inspection is unannounced by default, covers whatever the inspector decides to look at, takes as long as it takes, and cannot be stopped by the occupier.

Listing the differences makes clear that a third-party audit is not a weaker inspection. It is a different instrument with a different governing document, and the governing document is a commercial contract.

13.2 The announced audit specifically

Where customers required a minimum score on standard audits, but did not specify whether the audits were to be announced or unannounced, the supplier could ask to be notified some time prior, which could result in the auditor seeing a rather different facility than might be otherwise apparent.⁵

13.3 Why this is a contract design failure rather than a fraud

The buyer specified a score and did not specify the conditions under which it had to be achieved. Everything that followed was permitted by the terms.

That is a useful corrective to reading this as villainy. The requirement was written badly, and a badly written requirement gets satisfied in the cheapest available way.

14. How facilities prepare

What an announced audit produces, described by people who conduct them.

One auditor sent into a facility unannounced by a corporate office found that the facility shut down for a full week to prepare for its third-party audit, which it always passed with flying colors and a high score, but at the cost of a week's production. Additionally, many firms will also do pre-audits to help clients identify gaps, thus ensuring they will pass a full-blown audit.³

14.1 The week of production

A facility spending a week of lost output to prepare is not saving money by gaming the audit. It is paying a substantial amount to present a condition that is not its normal condition.

Which tells you the certificate is worth more than a week of production to them, and §15 is about why.

14.2 The pre-audit industry

Consultants engaged to find the gaps an auditor would find, so they can be closed before the auditor arrives.³

That is not inherently improper and can genuinely improve a facility. It also means the audit is measuring a prepared state rather than a routine one, and the two diverge by however much the preparation achieved.

15. The certificate as a marketing asset

Why the score matters commercially.

A high score on an audit can be a marketing advantage to a company. Many companies proudly display their certificates trumpeting their Superior, Excellent or Outstanding rating. They also use these documents in their marketing literature. However, these certificates do not always reflect what is going on in the plant.³

15.1 The incentive this creates

If the certificate has marketing value independent of the conditions it describes, then buying the certificate and improving the conditions are two different investments, and only one of them is directly rewarded.

That is our framing. The source reports the marketing use and the divergence without connecting them as an incentive argument.

16. What an auditor cannot do

The limits of the instrument, which are larger than most people assume.

Private auditors have no authority to stop production or to embargo or condemn food products; this can only be done by regulatory agencies that have legal authority. In fact, auditors have no legal authority, at all.²

16.1 The comparison with a regulator

A public health inspector arriving unannounced with statutory powers is a different instrument entirely. They choose the timing, set their own scope, and can close a premises.

Third-party audits grew because regulators were, in the words of one account, overwhelmed by the task of guarding the nation's food supply, so that monitoring has in large part fallen to an army of private auditors.¹ The substitute has none of the powers of the thing it substituted for.

16.2 What follows

An auditor who walks into a facility and sees something dangerous can write it down. They cannot halt anything, and they cannot require that anything be halted.

The report goes to the party who commissioned it, and what happens next is a commercial decision by somebody else.

17. Where the power actually sits

The correction to thinking of the auditor as the enforcer.

The true power in the third party model is the buyer. If the buyer is unhappy with the audit results, the buyer can cancel orders or put the supplier on some provisional status.²

17.1 Why buyers wrote weak specifications

Because a score is easy to administer across hundreds of suppliers and a well-designed audit specification is not. Requiring a minimum number can be checked by a purchasing clerk; requiring unannounced audits of stated duration and full scope requires somebody to understand what those things do.

That is the same substitution this journal found in canine detection certification and in pest control clearance reports: a legible number standing in for an assessment nobody has the capacity to make. It is our reading rather than a sourced one.

17.2 Why this matters for how the system could work

It locates the leverage correctly. The audit is information; the sanction is commercial and belongs to the purchaser.

A buyer who specifies unannounced audits, a minimum duration, full site scope and direct payment to the audit firm has a much better instrument than one who specifies a score. All four of those were available to the buyers in this case and none appear to have been used.

18. The snapshot objection

The general critique, stated by people who support audits.

Supporters argue third-party audits are a way to ensure food safety in an era of dwindling economic resources, while critics contend that while external audits and inspections can be a valuable tool to help ensure safe food, such activities represent only a snapshot in time.⁹

18.1 The resource argument deserves weight

The case for third-party auditing is not weak. Public inspection capacity is finite, food production is vast, and a system where buyers require assurance from suppliers extends oversight far beyond what regulators could reach.⁹

An article arguing only the failure side would be as unbalanced as the certificates in §15. The question is not whether to have third-party audits but what terms they are conducted under.

18.2 Why a snapshot is weak evidence about a process

Food safety is a continuous condition and an audit is a sample of one moment, chosen in advance by the party being sampled.

The previous article in this journal set out why a single observation cannot support inference about a state that varies. An audit is that problem with an additional feature: the observation time is negotiated with the thing being observed.

19. The regulatory response

What was subsequently required, at least for one category of audit.

Legislation created a system for recognising accreditation bodies that accredit third-party certification bodies to conduct food safety audits and issue certifications. The regulations must require audits to be unannounced and must contain protections against conflicts of interest between accredited third-party certification bodies and the entities they audit or certify, including requirements on timing and public disclosure of fees and appropriate limits on financial affiliations. The rule also establishes requirements for legal authority, competency, capacity, conflict of interest safeguards, quality assurance, and records procedures.⁶

19.1 Why unannounced is the single most effective provision

Because it disables everything in §14 at once. A facility cannot shut for a week to prepare for an audit whose date it does not know, and a pre-audit closing gaps has to close them permanently rather than temporarily.

It converts the measurement from a prepared state to a routine one, which is the only change that makes the observation representative of anything.

19.2 The two provisions that map onto this case

Unannounced, which addresses §13.1 and §14. And fee disclosure with limits on financial affiliations, which addresses §5 and §6.

The regulation identifies the same two failure modes this article has, which is reasonable external confirmation that the reading is correct.

19.3 The scope limitation

That framework governs a specific accreditation programme rather than private commercial audits generally. Separately, a qualified auditor is required to not have any financial conflicts of interests that influence the results of the verification activities, and the agency contemplates leveraging third-party audits as part of its overall compliance strategy while noting that audits are not required.⁷

So most commercial food safety auditing continues to operate under privately negotiated terms of the kind §13 describes.

20. What this means for a pest programme

The application to this trade, which is the reason we wrote it.

An audit does not validate the pest programme. It verifies that a documented programme exists, which §11 establishes directly.⁴

A passed audit is not evidence of absence of pests. The peanut facility is the demonstration.²

Documentation is part of what gets audited. Which means a contractor's paperwork determines an audit outcome regardless of whether it determines a pest outcome.

20.1 What an auditor can reasonably check about pest control

Not much, in a day, across a whole facility. Device placement against a site map, service report completeness, trend data, corrective actions, whether stations are secured and labelled, and whether what the reports say matches what is on the wall.

All of that is worth checking and none of it establishes whether the population is controlled. Section 12.1 is the distinction, and an auditor working to the time purchased in §6 is not in a position to close it.

20.2 The incentive this creates in the market

A pest control contractor can compete on documentation quality rather than on control, because documentation is what the client is assessed on and what a client can readily evaluate.

That is the credence goods structure of the preceding article in a specific form: a service optimised for the audit rather than for the building is cheaper to deliver and hard for a purchaser to distinguish from one that is not. We are naming the incentive because a client who knows it exists can specify against it, which is §21.

20.3 What a genuine programme has that a documented one may not

Effort recorded against findings, in the terms the previous article set out. Devices placed where the biology indicates rather than where a site map looks even. Trend data that is acted on rather than filed. And an honest account of what a negative finding is worth.

21. What we would tell a food premises client

Ask for unannounced. It is the provision the regulator made mandatory where it could.⁶

Specify duration and scope. Contracts can cap audit time.⁵

Know who is paying. The conflict is structural, not personal.¹

Treat the score as a floor, not a finding. Certificates do not always reflect the plant.³

The buyer holds the sanction. The auditor holds nothing.²

Judge the pest programme separately. On activity and on structural condition, not on files.

Ask your pest contractor what a clean report means. If the answer does not include how much was looked at, the report is a file rather than a finding.

22. Limitations and open questions

This is a case-led argument. One well-documented failure and one further reported case do not establish a base rate, and we located no study quantifying how often audits miss serious conditions.¹⁴

The sources are journalism, trade commentary and advocacy. A newspaper investigation reproduced by a plaintiffs' law firm, trade magazine articles, a consultancy page and a food safety blog, several with positions.¹³⁸⁹

The casualty figures conflict. Addressed in §8, and our reconciliation is inference.

The events are old. The principal case is from 2008 and 2009, and audit practice, scheme requirements and accreditation have changed substantially since, in part because of it.

This is United States material. Canadian food safety requirements, provincial inspection and the audit schemes operating here differ, and we have not sourced them.

We have not examined the major private schemes. The internationally recognised certification programmes have their own requirements on unannounced auditing, auditor competence and integrity which may already address much of §13, and we have not assessed them.

Sections 4.1, 4.2, 5.1, 8.1, 12, 13.2, 15.1, 17.1 and 20 are our reasoning. The visibility argument about rodent evidence, the reading of what it implies for pest programmes, the credence goods framing, the reconciliation of casualty counts, the document-against-outcome distinction, the contract design point, the incentive argument, the buyer leverage conclusion and the application to our own trade are ours rather than sourced positions.

Our position. We provide the kind of programme described in §20, and §20.2 names a market incentive that operates on every contractor in it. We think a purchaser is better served knowing the incentive exists and specifying against it, which is what §21 is for, than being told that paperwork and control are the same thing.

23. Conclusion

In March 2008 an auditor recorded that a peanut processing facility's overall food safety level was superior. He was working for its customers and being paid by the facility. He asked for more than the single day allotted and was told the extra time could be paid for at future audits.¹ The plant was very poorly maintained and had a serious rodent problem.² It had been shipping contaminated product for at least nine months, and the outbreak that followed is associated with seven to nine deaths and, depending on how they are counted, between around seven hundred and an estimated twenty-two thousand illnesses.¹⁴

The audit firm's own account of its method is the honest part: checking documents, making sure programmes are in place, checking equipment at a single point in time.⁴ That is what a conformance audit is. It was not what the buyers believed they had bought, and the terms they wrote, specifying a score without specifying surprise, duration or scope, permitted everything that happened.

For this trade the conclusion is narrow and uncomfortable. A facility can hold a complete, well-documented, fully compliant pest management programme and have rodents, and an audit built to examine documents will find the programme rather than the rodents. Our files are part of what gets inspected, which means we can be judged excellent by an instrument that would not have caught the worst failure in the sector's recent history. The building is the thing. The binder is evidence about the binder.

References

1. Food Safety Problems Slip Past Private Inspectors. Newspaper investigation reproduced by a plaintiffs' law firm. Source reproduced by a party with an interest in food safety litigation, cited as attributed material. Used for the auditor's recorded conclusion that the overall food safety level of the facility was considered to be superior, in a report dated 27 March 2008 for an institute that performs audits for major food companies, a copy of which was obtained by a national newspaper; for the statement that the auditor was inspecting the plant on behalf of a cereal manufacturer and other food companies while the audited corporation was paying him for his efforts; for the statement that federal investigators later discovered the dilapidated plant was ravaged by salmonella and had been shipping tainted peanuts and paste for at least nine months, in one of the nation's worst known outbreaks of foodborne disease in recent years in which nine are believed to have died and an estimated 22,500 were sickened; for the account that in auditing the plant the auditor became concerned about his ability to check it thoroughly and asked for more than the one day allotted, and that the corporation agreed to pay for the additional time but only in future audits; and for the report that a separate audit produced what that scheme's officials said was a low score, and that the company that paid for that audit, a large insurer, then sold the peanut company insurance to cover the costs of recalling products. https://marlerclark.com/news_events/food-safety-problems-slip-past-private-inspectors
2. Process and Substance in Third Party Food Safety Audits. Food safety and environmental health commentary. Used for the statement that although the facility was very poorly maintained and had a serious rodent problem, the auditor had several months before given the firm a superior rating; for the account that the corporation knowingly distributed contaminated peanut products causing a recall of over 4,000 different foods and taking seven lives; for the statement that private auditors have no authority to stop production or to embargo or condemn food products, which can only be done by regulatory agencies with legal authority, and that auditors have no legal authority at all; for the statement that under the contract the audited party can restrict the scope of the audit, stop an audit, or simply cancel it; and for the statement that the true power in the third party model is the buyer, who can cancel orders or place the supplier on provisional status if unhappy with the results. https://www.safefoodsblog.com/2014/07/food-safety/process-and-substance-in-third-party-food-safety-audits/
3. Third-party Audits: What the Food Industry Really Needs. Food safety trade magazine article. Used for the account of a facility that shut down for a full week to prepare for its third-party audit, which it always passed with a high score at the cost of a week's production; for the statement that many firms will also do pre-audits to help clients identify gaps so they will pass a full audit; for the statement that a high score can be a marketing advantage, that companies proudly display certificates trumpeting superior, excellent or outstanding ratings and use them in marketing literature, and that these certificates do not always reflect what is going on in the plant; for the report that the peanut corporation scored a superior rating from one auditing firm and 91 per cent from another; and for the observation that it is important to ensure corrective and preventive actions actually solve the root cause. https://www.food-safety.com/articles/4533-third-party-audits-what-the-food-industry-really-needs
4. Food Safety Conundrum: Third-Party Audits. Grocery trade publication. Used for the report that in 2010 a salmonella outbreak was traced to filthy conditions at two Iowa farms where hundreds of millions of eggs were recalled, one of which had received a superior rating from a named auditing organisation; for the report that the same organisation gave a superior rating in late 2008 to facilities operated by the peanut corporation, later found unsanitary and linked to at least nine deaths and nearly 700 illnesses; and for the 2009 statement by a spokesman for that organisation that its approach to auditing the facility involved checking documents, making sure programs are in place, and checking equipment at a single point in time. https://www.supermarketnews.com/food-safety/food-safety-conundrum-third-party-audits
5. A misunderstanding of third-party audits. Quality assurance and food safety trade commentary. Used for the statements that whether audits are announced or unannounced, and whether they cover an entire production facility or just the portions involved in manufacture of a particular product, are issues agreed upon by the customer and supplier without input from or knowledge of any regulatory entity; that in some cases the contracting parties even specify the maximum amount of time allowed to conduct an audit; that failure of a third-party audit to discover specific issues must first be investigated from the intent of the audit as contracted between the audit group, the customer and the supplier; and that where customers required a minimum score on standard audits but did not specify whether the audits were to be announced or unannounced, the supplier could ask to be notified some time prior, which could result in the auditor seeing a rather different facility than might otherwise be apparent. https://www.qualityassurancemag.com/news/qa-expert-blog-davis-third-party-audits/
6. Accreditation of Third-Party Certification Bodies To Conduct Food Safety Audits and To Issue Certifications. Federal Register, 27 November 2015. Regulatory source. Used for the account that legislation created a system for recognising accreditation bodies that accredit third-party certification bodies to conduct food safety audits and issue certifications; for the statement that the regulations must require audits to be unannounced and must contain protections against conflicts of interest between accredited third-party certification bodies and their audit agents and the entities they audit or certify, including requirements on timing and public disclosure of fees and appropriate limits on financial affiliations; and for the requirements established for legal authority, competency, capacity, conflict of interest safeguards, quality assurance and records procedures that certification bodies must demonstrate. https://www.federalregister.gov/documents/2015/11/27/2015-28160/accreditation-of-third-party-certification-bodies-to-conduct-food-safety-audits-and-to-issue
7. Third-Party Audits and FSMA. United States Food and Drug Administration. Regulatory guidance. Used for the requirement that a qualified auditor must not have any financial conflicts of interest that influence the results of verification activities, that audits consider applicable food safety standards, and for the statements that while audits are not required the agency contemplates leveraging third-party audits as part of its overall compliance strategy, building on current private audit activity and working with industry and other partners to strengthen the rigour and reliability of private audits. https://www.fda.gov/food/food-safety-modernization-act-fsma/third-party-audits-and-fsma
8. Third-Party Audits: Food Safety Consultant Auditors' Qualifications and Competencies Under the Microscope. Consultancy article. Commercial source with an interest in auditor competency services, cited as attributed material. Used for the observation that the peanut firm proudly touted on its website that it routinely underwent third-party auditing; for the question raised about the 2,100 companies who purchased product from the plant; for the report that in February 2009 a major cereal manufacturer openly stated it was reviewing how it qualifies food safety suppliers after its third-party auditor gave the Georgia plant a superior rating; and for the statement that differences in auditor competencies vary greatly. https://www.ehagroup.com/resources/articles/third-party-audits/
9. Food safety commentary and research summary on third-party audits. Academic food safety blog. Advocacy source with a stated critical position, cited as attributed material. Used for the summary that supporters argue third-party audits are a way to ensure food safety in an era of dwindling economic resources while critics contend that external audits and inspections, though a valuable tool, represent only a snapshot in time; for the reference to published work identifying limitations of food safety inspections and audits and recommending measures to strengthen the system; and for the assertion that the named auditing organisation has given very high ratings to some of the worst food offenders of the period. https://www.barfblog.com/tags/pca/